Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Whether penal interest constitutes a declared service under the toleration limb was addressed: the Tribunal applied the test that toleration requires a pre-agreed obligation to tolerate or refrain, and penal interest is compensatory, not consideration for toleration, hence not taxable. Whether liquidated damages/notice pay are taxable: recovery arises from the employeremployee relationship and is compensatory, not consideration for a service, and thus not exigible. Whether CSR payments amounted to sponsorship service: where consideration promotes brand visibility, sponsorship characterization applies and tax demand is sustainable absent documentary proof of pure donation; outcome: sponsorship-related demands upheld. Extended limitation and penalties were sustained where suppression with intent and nondisclosure were found, making interest and penalties payable.
Whether penal interest constitutes a declared service under the toleration limb was addressed: the Tribunal applied the test that toleration requires a pre-agreed obligation to tolerate or refrain, and penal interest is compensatory, not consideration for toleration, hence not taxable. Whether liquidated damages/notice pay are taxable: recovery arises from the employeremployee relationship and is compensatory, not consideration for a service, and thus not exigible. Whether CSR payments amounted to sponsorship service: where consideration promotes brand visibility, sponsorship characterization applies and tax demand is sustainable absent documentary proof of pure donation; outcome: sponsorship-related demands upheld. Extended limitation and penalties were sustained where suppression with intent and nondisclosure were found, making interest and penalties payable.
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